Clare McMullen | Lawyers

Admissions

UK (England & Wales)

Services

Financial Regulation Group

Sectors

Banks

Overview

Clare is a barrister specialising in contentious financial regulation.

Her clients include established and challenger banks, insurance companies, and asset managers. whom she advises on FCA and PRA enforcement investigations, the UK senior management and certification regime (SMCR), the Consumer Duty and anti-money laundering (AML) and financial crime compliance. She has advised on numerous large scale redress exercises.

Her practice includes advising on regulatory engagement, internal investigations and responding to regulatory enforcement investigations across a wide range of subjects. She has led investigations related to financial crime compliance, the Consumer Duty, cyber security, prudential issues and market conduct. She regularly advises clients on whistleblowing investigations and on matters involving allegations of non-financial misconduct. Her matters often involve managing the risks associated with parallel proceedings against firms and individuals and in multiple jurisdictions.

Clare’s practice includes supporting clients in responding to assertive supervision by the regulators, assisting firms on proposed business restrictions and on the provision of attestations by senior managers. She has particular expertise in the conduct of skilled person reviews under s166 FSMA, drawing on her experience leading a review to help firms prepare for and respond to skilled person reviews across a wide range of subjects.

Prior to joining Linklaters, Clare spent ten years within the Enforcement and Market Oversight Division of the Financial Conduct Authority. During that time, she led some of the regulator’s most high profile enforcement investigations, many with an international element. Matters included:

Corporate governance and senior management responsibilities
Insider dealing and market abuse
Fair treatment of customers
Listing rules breaches
Parallel investigations into FX misconduct

Clare has advised on contested applications for authorisation and approval, and has appeared before the FCA’s Regulatory Decisions Committee, the Upper Tribunal and the higher courts.

Experience

Advising a major lender over a multi-year period on all aspects of its motor finance commission work, including a skilled person review, cases before the FOS, litigation strategy and the response to the FCA consultation on an industry wide redress scheme.
Leading a cross practice team to support an asset manager respond to regulatory investigations and civil litigation, designing and implementing a £250M consumer redress exercise across multiple jurisdictions.
Conducting a wide ranging, business critical internal investigation into governance and management failings at a payments institution, supporting resolution of long standing issues with the regulator.
Advising London insurance market participants on responding to Lloyd’s investigations into suspected non financial misconduct.
Acting for established and challenger banks on FCA investigations into financial crime-related systems and controls failings.
Acting for a challenger bank on a joint PRA and FCA investigation involving parallel US litigation.
Acting for a major UK bank and the UK branch of a global bank on enforcement investigations into financial crime and AML systems and controls.
Advising a major UK retail bank on a skilled person review and subsequent enforcement investigation related to arrears handling.
Working within a cross practice crisis response team to assist clients in responding to major cyber security breach, advising on the necessary regulatory engagement both in the immediate aftermath of the breach and through restoration of service and subsequent remediation.
Acting for a major London market insurer on a PRA investigation into risk management systems and controls failings.
Assisting issuers and trading firms with their responses to pre-enforcement enquiries into suspected market misconduct in the equity and commodities markets.
Advising an asset manager in its response to an FCA Enforcement investigation closed without public action.

Recognition

Clare is ranked by Legal 500 as a Next Generation Partner in Financial services: contentious for 2026.

Beyond the Office

Prior to qualifying as a barrister, Clare worked as a management consultant at Oliver, Wyman & Company.

Education, Qualifications and Languages

Clare studied classics at Magdalen College, Oxford.

Thought Leadership

Clare contributes an annual overview of UK Financial Services Enforcement and Investigation to the GIR.

Overview

Clare is a barrister specialising in contentious financial regulation.

Corporate governance and senior management responsibilities

Insider dealing and market abuse

Fair treatment of customers

Listing rules breaches

Parallel investigations into FX misconduct

Clare has advised on contested applications for authorisation and approval, and has appeared before the FCA’s Regulatory Decisions Committee, the Upper Tribunal and the higher courts.

Experience

Advising a major lender over a multi-year period on all aspects of its motor finance commission work, including a skilled person review, cases before the FOS, litigation strategy and the response to the FCA consultation on an industry wide redress scheme.

Leading a cross practice team to support an asset manager respond to regulatory investigations and civil litigation, designing and implementing a £250M consumer redress exercise across multiple jurisdictions.

Conducting a wide ranging, business critical internal investigation into governance and management failings at a payments institution, supporting resolution of long standing issues with the regulator.

Advising London insurance market participants on responding to Lloyd’s investigations into suspected non financial misconduct.

Acting for established and challenger banks on FCA investigations into financial crime-related systems and controls failings.

Acting for a challenger bank on a joint PRA and FCA investigation involving parallel US litigation.

Acting for a major UK bank and the UK branch of a global bank on enforcement investigations into financial crime and AML systems and controls.

Advising a major UK retail bank on a skilled person review and subsequent enforcement investigation related to arrears handling.

Working within a cross practice crisis response team to assist clients in responding to major cyber security breach, advising on the necessary regulatory engagement both in the immediate aftermath of the breach and through restoration of service and subsequent remediation.

Acting for a major London market insurer on a PRA investigation into risk management systems and controls failings.

Assisting issuers and trading firms with their responses to pre-enforcement enquiries into suspected market misconduct in the equity and commodities markets.

Advising an asset manager in its response to an FCA Enforcement investigation closed without public action.

Admissions

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Overview

Experience

Recognition

Beyond the Office

Education, Qualifications and Languages

Thought Leadership

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Overview

Experience

Recognition

Beyond the Office

Education, Qualifications and Languages

Thought Leadership